Evan Dumas 

You’re listening to Group Practice Tech, a podcast by Person Centered Tech, where we help mental health group practice owners ethically and effectively leverage tech to improve their practices. I’m your co-host, Evan Dumas.

 

Liath Dalton 

And I’m Liath Dalton, and we are Person Centered Tech.

 

Liath Dalton 

This episode is brought to you by Therapy Notes. Therapy Notes is a robust online practice management and electronic health record system to support you in growing your thriving practice. Therapy Notes is a complete practice management system with all the functionality you need to manage client records, meet with clients remotely, create rich documentation, schedule appointments and bill insurance all right at your fingertips. To get two free months of Therapy Notes as a new Therapy Notes user go to therapynotes.com and use promo code PCT.

 

Evan Dumas 

Hello and welcome to Episode 538: Medicare Teletherapy: What’s Happening Right Now.

 

Liath Dalton 

And the right now is so key.

 

Liath Dalton 

So what has prompted us to be doing a another podcast episode on this topic, just a short, I don’t know, five weeks after the last time we talked about this, is that things have indeed changed since our last episode.

 

Liath Dalton 

Our last episode about this was just saying, basically, we don’t know what’s going to happen yet there will not be clarity until the end of September, and when that clarity arrives, we will provide as much supportive information and specific guidance as possible.

 

Liath Dalton 

So we have now done that, and we are recording this right after having done a free webinar with Gabrielle from Medicare Consulting for Therapists last Friday, and so we thought we’ll just share some of the most important takeaways and distillations from that with all of you.

 

Evan Dumas 

Yeah, yeah. And I’m so glad we’re doing so because this webinar was so well attended. We had so many folks on, and everyone had so many questions and was generally very anxious, because it’s true in times where you can’t get official answers due to government shutdowns and whatnot, you need to get them from your peers and from known experts in the field.

 

Evan Dumas 

And so this little podcast is going to be just the briefest little tidbit covering of that, but I’m going to really recommend folks go and watch the free webinar recording that we have of this. So you can get that on our site, and it’s an hour and a half long. We address so much of this, and we also tell you where to go for more support afterwards, if you have a special sort of edge case or unique scenario, something like that.

 

Liath Dalton 

Exactly. And like we say, that is freely available. We are really committed to our purpose as an organization of providing confidence and clarity and support and trying to make the hard pieces of all of these shifting regulations and their impact on your practice as navigable as possible. So please do check that out, and then in the meantime, we’ll just give you kind of the cliff notes version, right?

 

Liath Dalton 

So first of all, the main, main piece is that there is no telehealth cliff for teletherapy, for behavioral health, slash mental health care services.

 

Liath Dalton 

That was a big anxiety that a lot of folks had, and thankfully, we knew that those extensions and provisions were made permanent, and so that is not something that is in question or even in potential jeopardy. That is solid. Teletherapy for behavioral and mental health care services continues to be covered, and the reimbursement rates have not changed for the provision of those services.

 

Evan Dumas 

Nope.

 

Liath Dalton 

Right?

 

Evan Dumas 

Nope.

 

Liath Dalton 

So that’s a big deal that should hopefully take some of the panic out of everyone’s nervous systems, right?

 

Evan Dumas 

Yeah.

 

Liath Dalton 

The next piece is that audio only also continues to be covered for everyone and for behavioral health, specifically. So Speech Language Pathologists and some of the like adjacent professions that we support from time to time, that is not the case for you, unfortunately, but for traditional behavioral mental health support, audio only is still covered.

 

Liath Dalton 

And in the instance that you are doing audio only telehealth, what you want to be doing in terms of your billing and coding is using modifier 93, which indicates audio only. And that’s totally fine, so long as the client either can’t or doesn’t want to use video. You, as the provider, still have to have the capability of doing a video session, but that’s sort of as far as the parameters for what makes it possible for a audio only session to be covered, covered are so nothing too complex or onerous there, thankfully.

 

Evan Dumas 

No no.

 

Liath Dalton 

Yeah. And then the next big things, of course, are really related to what has changed.

 

Liath Dalton 

And so what has changed is the in-person visit requirement. Now, thankfully, CMS was kind enough to release a FAQ with a lot of clarifying guidance on October 15, 2025. And in that, they were really explicit about what the differentiating marker between an established client and a new client is, in terms of how they apply the in-person visit requirement.

 

Evan Dumas 

Mhm, yeah.

 

Liath Dalton 

So the good news is that the in-person visit rule applies to all new clients.

 

Evan Dumas 

Mhm.

 

Liath Dalton 

And that any new client that you are going to start providing care to must, must have an in-person visit within six months before starting teletherapy again. That is before, prior to, and there are no exceptions to that requirement.

 

Evan Dumas 

No.

 

Liath Dalton 

Thankfully, thankfully, the things are a little bit different when it comes to established clients. And part of the clarifying guidance that CMS, so the Centers for Medicaid and what’s the S stand for, I don’t know. We live in acronym soup.

 

Evan Dumas 

Yeah, yeah totally.

 

Liath Dalton 

Anyway, the clarifying guidance the CMS issued regarding what constitutes an established client versus a new client is that any client who has been seen via teletherapy for behavioral or mental health care prior to October 1, so up to and through September 30, 2025, will be considered an established client.

 

Evan Dumas 

Yeah.

 

Liath Dalton 

One of the like clarifying questions that we got from folks was, well, what if I saw them on a private pay or other insurance basis previously, and now they’re covered by Medicare, and so billing’s going through Medicare like post that date, time shift, right. And the clarifying guidance also thankfully specifies that if Medicare would have covered it, then they are considered established, right? So that that part is helpful.

 

Liath Dalton 

So basically, when it comes to established clients, they need to have an in-person visit every 12 months, so on an annual basis, and thankfully, there are also exceptions. The sort of challenging piece about the exceptions is that they are only specific to client circumstances. So if there would be undue hardship for health, or mobility, or travel reasons for the client.

 

Liath Dalton 

Yeah, for the client.

 

Liath Dalton 

For the client, yeah, or it’s clinically contraindicated, then there is an exception, or, in the official lingo, a deferment of the annual visit requirement. So the sad reality of it is that like therapist disability or travel restrictions do not qualify at this point in time for the exception.

 

Liath Dalton 

So for your established clients that are Medicare based clients, you will need to make a provision for in-person visits if they do not qualify for one of the valid exceptions. But the good news is you’ve got lots of time to do that, right?

 

Evan Dumas 

Yeah, yeah, totally.

 

Liath Dalton 

Plenty, plenty of time to do that. And, there is also the very real possibility that, well, very real. There is the possibility that Congress will get their A into G and make the in-person requirement not applicable for mental and behavioral health care.

 

Evan Dumas 

Yeah, hopefully.

 

Liath Dalton 

Right? Maybe. Maybe. I don’t want folks to bank on that,

 

Evan Dumas 

No, no.

 

Liath Dalton 

and that’s part of why the guidance that Gabrielle and I were giving during the webinar was this may change. It’s not like a urgency or immediacy situation, though. 

 

Liath Dalton 

So, don’t want people panicking when it comes to continuing to provide care to established clients. Rather, keep checking back periodically, not like on a daily basis, where it just floods you and makes you feel overwhelmed, but you know you can check in monthly, and hopefully within at least six, six months prior to, or three months prior to this actually going into effect, we’ll know if, if that’s really going to be how things are on a permanent basis.

 

Liath Dalton 

And if they are and you have some clients who don’t qualify for the exception conditions for in-person requirement, then make a plan to either see them in-person, which, if you’re providing care from a different state, of course, that’s going to have additional layers to it, but those are still navigable, or to refer them out.

 

Liath Dalton 

And part of why we’re giving that six month to three month timeframe is because if the end solution is that you do need to refer a handful of clients out, then you want to have sufficient time to really allow for that, like continuity of care piece to be fully in place.

 

Evan Dumas 

Yeah.

 

Liath Dalton 

Right?

 

Evan Dumas 

Yeah.

 

Liath Dalton 

Yeah. So that’s, that’s really the main thing. Let’s see. A couple other key pieces that everyone was was asking about were the differences between the traditional Medicare, Medicare Part B, and Medicare Advantage plans. Well, the news there is that traditional Medicare is what is like nationally, federally applicable. Medicare Advantage plans, so part T plans typically will follow the same federal Medicare rules for telehealth, but the coverage and implementation can really vary plan by plan.

 

Evan Dumas 

Mhm.

 

Liath Dalton 

So with any Medicare Advantage specific plan, folks, you want to be verifying details directly with the Medicare Advantage plan or through their provider portal, and that’s unfortunately, we don’t have more clarity than that.

 

Evan Dumas 

No.

 

Liath Dalton 

So try and track, or create a system for tracking, who you have that is a traditional Medicare client versus a Medicare Advantage client. And then, Medicaid is not the same thing as Medicare.

 

Evan Dumas 

No.

 

Liath Dalton 

Right? And Medicare is federal, national right. Medicaid is state based.

 

Evan Dumas 

Mhm.

 

Liath Dalton 

And so that’s going to vary state, state by state. And so far, we haven’t seen as many changes to Medicaid teletherapy coverage, as we have with the Medicare Advantage Plans, applying things.

 

Liath Dalton 

But I do want to say, and thanks to one of our community members for sharing relevant info about the Medicare Advantage plans. So they’re a provider in the Kaiser network, and the Kaiser network shared with them that it was following the full federal Medicare Part B standards, for the with the in-person visit requirement, both for new patients, of course, which, again, no exception to that, and to established patients, within 12 months. So that’s kind of the lay of the land. Check out the full recording of the free webinar to get all of the nuances and details.

 

Liath Dalton 

And we just want folks to feel equipped to be able to manage this aspect of continuing to provide client care and manage their practices, and hopefully not feel too distressed. I know it’s a challenging time to be a human, and there are a lot of things impacting everyone, both personally and professionally, but this is is not as dire as it seemed initially, or maybe as some of the news stories about it that were related to other different provider types made it seem. So it’s not all doom and gloom. It will be okay, and we will continue to keep you apprised of developments as as they become available and as they impact your practice.

 

Liath Dalton 

Thanks for joining us, and we’ll chat with you folks next week.

 

Evan Dumas 

Yeah, talk to you next week, everybody.

 

Liath Dalton 

This has been Group Practice Tech. You can find us at personcenteredtech.com. For more podcast episodes, you can go to personcenteredtech.com/podcast or click podcast on the menu bar.